Furthermore, Appellants correctly argue the Examiner’s reliance on routine optimization is improper. Modifications that would have been known to a person of ordinary skill are irrelevant to whether a reference anticipates a claim under 35 U.S.C. § 102. Titanium Metals Corp. v. Banner, 778 F.2d 775, 780 (Fed. Cir. 1985) (“[A]nticipation under § 102 can be found only when the reference discloses exactly what is claimed and that where there are differences between the reference disclosure and the claim, the rejection must be based on § 103 which takes differences into account.”) Still further, even under 35 U.S.C. § 103(a), the failure to provide sufficient evidence “that one skilled in the art would necessarily have appreciated the advantageous effects of providing a nitride insulating film in a semiconductor device within the claimed range” (App. Br. 13) renders a rejection based on obviousness improper.